Discuss how the *M.K. Ranjitsinh* judgment reframes the conflict between India's climate commitments and biodiversity obligations.

Q. Discuss how the M.K. Ranjitsinh judgment reframes the conflict between India's climate commitments and biodiversity obligations. (15 marks, 250-350 words)

Conservation debates in India have traditionally pitted development against ecology. M.K. Ranjitsinh v. Union of India (2024 INSC 280) disturbs that binary: here both contending claims are green — solar expansion in the Thar for India's climate targets versus survival of the Critically Endangered Great Indian Bustard, whose principal human-caused mortality is power-line collision [1][2].

The conflict as originally framed - The Court's 2021 order treated the clash as species-versus-infrastructure, directing blanket undergrounding of transmission lines across priority and potential GIB habitat in Rajasthan and Gujarat [1]. - This assumed biodiversity protection carries little climate cost — an assumption the Union contested on grounds of feasibility, cost and the scale of evacuation capacity needed for renewables [1].

How the judgment reframes it - Green-versus-green, not green-versus-growth: the Court expressly recognised the "nuanced interplay" between safeguarding biodiversity and mitigating climate change, rejecting the conventional sustainable-development framing [1]. - Rights-based grounding: it read a right against the adverse effects of climate change into Articles 14 and 21, so India's solar push acquires constitutional weight rather than being a mere policy preference [1]. - From judicial fiat to expert calibration: the blanket direction was modified and an expert committee substituted, allowing habitat-specific mitigation — bird diverters, selective undergrounding, corridor planning — instead of a uniform rule [1]. - Treaty obligations retained: India's duties under CMS Appendix I (COP-13, Gandhinagar, 2020) and Schedule I of the Wildlife (Protection) Act, 1972 remain the floor the balancing must respect [2]. - Ex-situ effort as complement: Project GIB's captive stock reaching 94 birds in June 2026 buys time, but cannot substitute for a safe wild habitat [3].

The judgment's real contribution is method — it converts an either/or into a proportionality exercise, insisting that climate action and species recovery be optimised together rather than traded off. Going forward, mandatory bird-diverter norms, ecologically-informed siting of solar parks under the expert panel's supervision, and continued in-situ habitat restoration alongside conservation breeding [4] can make India's energy transition genuinely consistent with its biodiversity commitments and SDG 15.

(~330 words)

Sources: 1. M.K. Ranjitsinh & Ors. v. Union of India, 2024 INSC 280 (Supreme Court, 21 March 2024) — 2021 undergrounding order, its modification, expert committee, and the Article 14/21 right against climate change 2. CMS COP-13 Proposal for Inclusion of the Great Indian Bustard in Appendix I (India) — power-line collision as principal anthropogenic mortality factor; CMS Appendix I listing 3. Project GIB Adds Three Chicks, Taking Captive Stock to 94 Birds (PIB, 14 June 2026) — captive stock of 94 birds in the fourth breeding season 4. Protection of Great Indian Bustards / Conservation Plan (PIB, MoEFCC) — habitat improvement and conservation-breeding programme run by MoEFCC with WII and state forest departments